Guilty Plea Agreement — U.S. v. Dawnikia Hunt (E.D. Mo.)
Summary
A guilty plea agreement in United States of America v. Dawnikia Bruceatte Hunt, a/k/a Dawnika Hunt, Case 1:25-cr-00047-CMS, in the United States District Court for the Eastern District of Missouri, filed January 20, 2026 as Doc. #: 36. The defendant agrees to plead guilty to the indictment, charging a false statement to a financial institution and wire fraud, and to pay $19,960.00 in restitution. The agreed facts state that the defendant applied for a PPP loan with Fountainhead Small Business Finance, LLC on May 1, 2021 using a fraudulent IRS Schedule C, and that Fountainhead deposited $19,960.00 on May 14, 2021. The parties estimate a total offense level of 9, from a base offense level of 7, with 4 levels added for loss and two deducted for acceptance of responsibility. The defendant also agrees to a $200 special assessment and to appeal and post-conviction waivers.
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Cite this document
“Guilty Plea Agreement — U.S. v. Dawnikia Hunt (E.D. Mo.).”
Original at ecf.moed.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-usa-v-hunt-dkt-36-e-d-mo-bdbe2ca93b/
, SHA-256 0a52b416335a833b2ab5051b9cc3e03118ca131dc52dbd1d9fcee717f610fa16.Full text
Case: 1:25-cr-00047-CMS Doc. #: 36 Filed: 01/20/26 Page: 1 of 12 PageID #: 92
UNITED STATES DISTRICT COURT
• EASTERN DISTRICT OF MISSOURI PILED
SOUTHEASTERN DNISION
JAN 20 2026
UNITED STATES OF AMERICA, )
) l:A~·TlR~ tWf~r/DURT
1
Plaintiff, ) CAPE GiRARoMlJ Mo
) NO. 1:25 CR 47 c·/11 f
V. )
)
DAWNIKIA BRUCEATTE HUNT, )
a/k/a, Dawnika Hunt, )
)
Defendant. )
GUILTY PLEA AGREEMENT
\ j
Come now the parties and hereby agree, as follows:
1. PARTIES:
The parties are the defendant Dawnikia Bruceatte Hunt, represented by defense counsel
Jennifer L. Booth, and the United States of America, (hereinafter "government"), represented by
the Office of the United States Attorney for the Eastern District of Missouri. This agreement
does not, and is not intended to, bind any governmental office or agency other than the United
States Attorney for the Eastern District of Missouri. The Court is neither a party to nor bound by
this agreement.
2. GUILTY PLEA:
Pursuant to Rule 11 (c)(1 )(A), Federal Rules of Criminal Procedure, in exchange for
defendant's voluntary plea of guilty to the indictment, the government agrees that- no further -
federal prosecution of the defendant will be brought in this District relative to the underlying
facts supporting the charges ~n the indictment herein, of which the governm'ent is aware at this
time. The defendant also agrees to pay $19,960.00 in restitution to the United States of America
Case: 1:25-cr-00047-CMS Doc. #: 36 Filed: 01/20/26 Page: 2 of 12 PageID #: 93
as a part of this plea.
Furthermore, the parties agree that either party may request a sentence above or below the
U.S. Sentencing GuicJ.elines range (combination of Total Offense Level and Criminal History
Category) ultimately determined by the Court pursuant td any chapter of the Guidelines, Title 18
United States Code, Section 3553, or any other provision or rule of law not addressed herein. The
parties further agree that notice of any such request will be given no later than teh (10) days prior
to sentencing and that said notice shall specify the legal and factual bases for the request.
3. ELEMENTS:
The crime of making a false statement to a financial institution, as charged in Count I of
the Indictment, has three elements, which are: One, the defendant knowingly made false
statements, namely that the defendant was the owner of a qualifying small business, and that PPP
loan proceeds would be spent on permissible expenses, to a financial institution; Two, the
defendant made the false statement for the purpose of influencing the action of the financial
institution upon an application for a PPP loan; and Three, that the financial institution was backed
by the Small Business Administration at the time the statement was made.
The crime of wire fraud, as charged in Count II of the indictment, has four elements, which
are: One, the defendant voluntarily and intentionally participated in a scheme to obtain money by
means of material false representations, namely the submission of a fraudulent PPP Loan
application, Two, the defendant did so with the intent to defraud; Three, the defendant used, or
caused to be used, an interstate wire communication, that is, the use of an internet loan application
portal, in furtherance of some essential step in the scheme; and Four, the scheme affected a
financial institution.
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4.FACTS:
The parties agree that the facts in this case are as follows and that the Government would
prove these facts beyond a reasonable doubt if the case were to go to trial. These facts may be
considered as relevant conduct pursuant to Section lB 1.3:
The Coronavirus Aid, Relief, and Economic Security ("CARES") Act is a federal law
that was enacted in or around March of 2020 to provide emergency financial assistance to the
millions of Americans suffering the economic impact caused by the COVID-19 pan~emic. The
'
CARES Act authorized the Small Business Administration (SBA) to issue forgivable loans to
small businesses for job retention and certain other expenses through the Paycheck Protection
Program ("PPP").
To obtain a PPP loan, a qualifying business was required to submit a PPP loan
application, signed by an auth?rized representative of the business who was required to certify
that, among other things, the small business was in operation on February 15, 2020,.and that
SBA loan proceeds will be used only for business-related purposes as specified in the loan
application and consistent with the Paycheck Protection Program Rules, such as retaining
workers, maintaining payroll, making mortgage interest payments, lease payments, and utility
payments. The program also required the submission of certain documents related to the identity
~
of the applicant and the expenses of the business, like payroll, that would be covered by the
loans.
Dawnikia Bruceatte Hunt, of Caruthersville, Pemiscot County Missouri was identified as
a person who had filed via an interactive. internet portal, which constitutes an interstate wire
communication, a fraudulent application for a PPP loan with Fountainhead Small Business
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Finance, LLC, of Lake Mary, Florida. Fountainhead was an SBA approved financial institution
for the PPP Loan program. Dawnikia Hunt did not own or operate an eligible business and had
submitted a fraudul~nt IRS Schedule C to obtain the loan. Dawnikia Hunt had also uploaded a
copy of her photo and Missouri driver's license to the website to prove her identity. Dawnikia
Hunt ,applied for a loan on May 1, 2021, and Fountainhead deposited the proceeds, $19,960.00 •
into her bank account on May 14, 2021.
Agents conducted a non-custodial interview of Dawnikia Hunt, who indicated that she had
been assiste9 by someone else in applying for the loan, and that the IRS Schedule C contained
false information.
As a part of this plea the defendant admits that she knowingly made false statements to a
financial institution backed by the SBA for the purpose of obtaining a loan. She also admits that
she voluntarily and intentionally participated in a scheme to obtain money, affecting a financial
institution, by means of making materially false representations via an interstate wire
communication and that she did so with the intent to defraud.
5. STATUTORY PENALTIES:
The defendant understands that the maximum possible penalty as to each Count herein is
not more than 30 years of imprisonment, a fine of not more than $1,000,000, or both a fine and
imprisonment and a term of supervised release of not more than five years.
In the event defendant is subject to any undischarged or anticipated term of imprisonment
imposed by any court, defendant has been apprised by counsel that the sentence imposed in this
case may be imposed consecutively to the undischarged or anticipated term of imprisonment.
6. U.S. SENTENCING GUIDELINES: 2024 MANUAL:
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' '
The defendant understands that this offense is affected by the U.S. Sentencing Guidelines
and the actual sentencing range is determined by both the Total Offense Level and the Criminal
History Category. The parties agree that the following are the U.S. Sentencing Guidelines Total
Offense Level provisions that apply.
(1) Chapter 2 Offense Conduct:
(a) Base Offense Level: The parties agree that the base offense level is 7 as found
in Section 2Bl.l(a)(l).
(b) Specific Offense Characteristics: The parties agree that the following
Specific Offense Characteristics apply: 4 levels should be added pursuant to Section
2Bl.l(b)(l)(C) because the loss exceeded $15,000.00.
(2) Chapter 3 Adjustments:
(a) Acceptance of Responsibility: The parties recommend that two levels should
be deducted pursuant to Sentencing Guidelines Section3El.l(a) because Defendant has clearly
demonstrated acceptance of responsibility.
The parties agree that if Defendant does not abide by all of the agreements made within
this document, Defendant's failure to co111ply is grounds for the loss of acceptance of
responsibility pursuant to Sentencing Guidelines Section 3El .1. The parties further agree that
Defendant's eligibility for a reduction pursuant to Sentencing Guidelines Section 3El .1 is based
upon the information known at the present time and that any actions of Defendant which occur or
which become known to the United States subsequent to this agreement and are inconsistent with
,
Defendant's acceptance of responsibility including, but not limited to criminal conduct, are
grounds for the loss of acceptance of responsibility pursua~t to Sentencing-Guidelines Section
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3El.l. In any event, the parties agree that all of the remaining provisions of this agreement
remain valid and in full force and effect.
(b) Other Adjustments: The parties recommend that no additional adjustments apply.
(c) Estimated Total Offense Level: The parties estimate that the Total Offense Level is
9.
_)
/
(d) Criminal History: The determination of the defendant's Criminal History Category
shall be left to the Court. Either party may challenge, before and at sentencing, the finding of the
Presentence Report as to the defendant's criminal history and the applicable category. The
defendant's criminal history is known to the defendant and is substantially available in the
Pretrial Services Report.
(e) Effect of Parties' U.S. Sentencing Guidelines Analysis: The parties agree that the
Court is not bound by the Guidelines analysis agreed to herein. The parties may not have
foreseen all applicable Guidelines. The Court may, in its discretion, apply or not apply any
Guideline despite the agreement herein and the parties shall not be permitted to withdraw from
the plea ~greement.
7. WAIVER OF APPEAL AND POST-CONVICTION RIGHTS:
a. Appeal:· The defendant has been fully apprised by defense counsel of the defendant's
rights concerning appeal and fully understands the right to appeal the sentence under Title 18,
United States Code, Section 3742.
(1) Non-Sentencing Issues: The parties waive all rights to appeal all non-jurisdictional,
non-sentencing issues, including, but not limited to, any issues relating to pretrial motions,
discovery and the guilty plea, the constitutionality of the statute(s) to which the defendant is
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pleading guilty and whether defendant's conduct falls within the scope of the statute(s)
{2) Sentencing Issues: In the event the Court accepts the plea, accepts the U.S.
Sentencing Guidelines Total Offense Level agreed to herein, and, after determining a Senter:icing
Guidelines range, sentences the defendant within or below that range, then, as part of this
agreement, the defendant hereby waives all rights to appeal all sentencing issues other than
Criminal History, but only if it affects the Base Offense Level or Criminal History Category.
Similarly, the Government hereby waives all rights to appeal all sentencing issues otlier than
Criminal History, provided the Court accepts the plea, adopts the agreed Total Offense Level and
, sentences the defendant within or above that range.
b. Habeas Corpus: The defendant agrees to waive all rights to contest the conviction or
sentence in any post-conviction proceeding, including one pursuant to Title 28, United States
Code, Section 225 5, except for claims of prosecutorial misconduct or ineffective assistance of
counsel.
c. Right to Records: The defendant waives all rights, whether asserted directly or by a
representative, to request from any department or agency of the United States, any records
pertaining to the investigation and prosecution of this case, including any records that may be
sought under the Freedom of Infonnation Act, Title 5, United States Code; Section 522, or the
Privacy Act, Title 5, United States Code, Section 552(a).
8.0THER:
a. Disclosures Required by the United States Probation Office: The defendant agrees
to truthfully complete and sign forms as required by the United States Probation Office prior to
sentencing and consents to the release of these forms and any supporting documentation by the
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United States Probation Office to the government.
b. Civil or Administrative Actions not Barred; Effect on Other Governmental
Agencies:
Nothing contained herein limits the rights and authority of the.United States to take any
civil, tax, immigration/deportation or administrative action against the defendant.
c. Supervised Release: Pursuant to any supervised release term, the Court will impose
standard conditions upon the defendant and may impos~ special conditions related to the crime
the defendant committed. These conditions will be restrictions on the defendant to which the
defendant will be required to adhere. Violation of the conditions of supervised release resulting
in revocation may require the defendant to serve a term of imprisonment equal to the length of
the term of supervised release, but not greater than the term set forth in Title 18, United States
:
Code, Section 3583(e)(3), without credit for the time served after release. The defendant
understands that parole has been abolished.
d. Mandatory Special Assessment: Pursuant to Title 18, United States Code, Section
3013, the Court is required to impose a mandatory special assessment of $100 per count for a
total of $200, which the defendant agrees to pay at the time of sentencing. Money paid by the
defendant toward any restitution or fine imposed by the Court shall be first used to pay any
unpaid mandatory special assessment.
e. Possibility of Detention: The defendant may be subject to immediate detention
pursuant to the provisions of Title 18, United States Code, Section 3143.
f. Fines, Restitution and Costs oflncarceration and Supervision: The Court may
impose a fine, costs of incarceration and costs of supervisiop.. The defendant agrees that any fine
imposed by the Court will be due and payable immediately. The defendant agrees to pay
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100
$19,960.00 in restitution to the United States of America.
g. Forfeiture: The defendant knowingly and voluntarily waives any right, title, and interest
in all items seized by law enforcement officials during the course of their investigation, whether
or not they are subject to forfeiture, and agrees not to contest the vesting of title of such items in
the United States. The defendant agrees to abandon her interest in all seized items and further
agrees that said items may be disposed of or destroyed by law enforcement officials in any manner
without further notice. By abandoning these items, the defendant waives any future rights to
receive additional notice, a valuation ofthe items, or the opportunity to submit a claim to contest
the disposition or destruction of the items that may exist under any policies or procedures of the
seizing agency(ies).
9. ACKNOWLEDGMENT AND WAIVER OF THE DEFENDANT'S RIGHTS:
In pleading guilty, the defendant acknowledges, fully understands and hereby waives his
rights, including but not limited to: the right to plead not guilty to the charges; the right to be
tried by a jury in a public and speedy trial; the right to file pretrial motions, including motions to
suppress or exclude evidence; the right at such trial to a presumption of innocence; the right to
require the government to prove the elements of the offenses charged against the defendant
beyond a reasonable doubt; the right not to testify; the right not to present any evidence; the right
to be protected from compelled self-incrimination; the right at trial to confront and cross-
examine adverse witnesses; the right to testify and present evidence and the right to compel the
attendance of witnesses. The defendant further understands that by this guilty plea, the
defendant expressly waives all the rights set forth in this paragraph.
• The defendant fully understands that the defendant has the right to be represented by
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101
counsel, and if necessary, to have the Court appoint counsel at trial and at every other stage of
the proceeding. The defendant's counsel has explained these rights and the conse·quences of the
waiver of these rights. The defendant fully understands that, as a result of the guilty plea, no trial
will, in fact, occur and that the only action remaining to be taken in this case is the imposition of
the sentence.
The defendant is fully satisfied with the representation received from defense counsel.
The defendant has reviewed the government's evidence ~nd discussed the government's case and
all possible defenses and defense witnesses with defense counsel. Defense counsel has
completely and satisfactorily explored all areas which the defendant has requested relative to the
government's case and any defenses.
The terms and conditions contained in this stipulation constitute the only plea offer which
has been tendered to the defendant by the Government herein. Defendant has fully discussed the
terms and conditions of the offer with counsel and the defendant understands and agrees tci the
same.
10. VOLUNTARY NATURE OF THE GUILTY PLEA AND PLEAAGREEMENT:
This document constitutes the entire agreement between the defendant and the
government, and no other promises or inducements have been made, directly or indirectly, by
any agent of the government, including any Department of Justice attorney, concerning any plea
to be entered in this case. In addition, the defendant states that no person has, directly or
indirectly, threateried or coerced the defendant to do or refrain from doing anything in
connection with any aspect of this case, including entering a plea of guilty.
The defendant acknowledges having voluntarily entered into both the plea agreement and
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102
the guilty plea. The defendant further acknowledges that this guilty plea is made of the
defendant's own free will and that the defendant is, in fact, guilty.
11. CONSEQUENCES OF POST-PLEA MISCONDUCT:
After pleading guilty and before sentencing, if defendant commits any crime, other than
minor traffic offenses, violates
•
any conditions of release that results in revocation, violates
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any·· 1
term of this guilty-plea agreement, intentionally provides misleading, incomplete or untruthful
information to the U.S. Probation Office or fails to appear for sentencing, the United States, at its
option may be released from its obligations under this agreement. The Government may also, in
its discretion, proceed with this agreement and may advocate for any sentencing position
supported by the facts, including but not limited to obstruction of justice and denial of
acceptance of responsibility.
12. NO RIGHT TO WITHDRAW GUILTY PLEA:
Pursuant to Rule 11(c) and (d), Federal Rules of Criminal Procedure, the defendant
understands that there will be no right to withdraw the plea entered under this agreement, except
where the Court rejects those portions of the plea agreement which deal with charges the
government agrees to dismiss or not to bring.
/Z-31-l.S
Date
~va
Tim J. Willi~MO
Assistant United States Attorney
555 Independence Street, Suite 3000
Cape Girardeau, Missouri 63703 ,
{)~1}v4-
Dawnikia Bruceatte Hunt
Defendant
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Case: 1:25-cr-00047-CMS Doc. #: 36 Filed: 01/20/26 Page: 12 of 12 PageID #:
103
t e nifer
:Ass· ederal Public Defender
325 Broadway, Second Floor
Cape Girardeau, Missouri 63701
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